October 2018

REGULATORY DEVELOPMENTS

IRS Releases Guidance on Uniform Mortgage-Backed Securities for Purposes of § 817(h)

On October 16, the IRS released an advanced version of Revenue Procedure 2018-54, which provides guidance and procedural rules that allow taxpayers (i.e., issuers of variable contracts in this case) to elect to utilize a “deemed-issuer ratio” for “generic GSE securities” in order to comply with IRC § 817(h) diversification requirements.


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